GR L 20988; (September, 1966) (Digest)
G.R. No. L-20988 September 27, 1966
JACINTO DECENA, petitioner, vs. THE COURT OF AGRARIAN RELATIONS, FAUSTINO BANDALES, AQUILINO SOGONI and AGAPITO BANDALES, respondents.
FACTS
The spouses Timoteo Bandales and Agatona Decena owned three parcels of land. They executed a “deed of extrajudicial partition” in 1938, dividing the lots and donating them to third parties. Upon the spouses’ deaths, their nephews (Faustino Bandales, Agapito Bandales, and Aquilino Sogoni) filed a case to annul the donation and be declared heirs. The Court of Appeals ultimately declared the donation void for lacking the formalities of a will and recognized the nephews as the legal heirs and exclusive owners of the lots. This decision became final. Jacinto Decena had been the tenant of portions of the land since 1927, when it was still owned by the spouses. As a result of a writ of execution issued after the Court of Appeals decision, Decena was dispossessed of his landholdings in November 1961. Decena then filed a suit in the Court of Agrarian Relations for reinstatement and damages, alleging his dispossession violated the Agricultural Tenancy Act. The agrarian court dismissed his case, ruling that his previous landholders (the donees) were not the true owners. Decena appealed to the Supreme Court.
ISSUE
Whether the Court of Agrarian Relations erred in dismissing Jacinto Decena’s petition for reinstatement on the ground that his previous landholders were not the true owners of the land.
RULING
Yes. The Supreme Court reversed the order of the Court of Agrarian Relations. The Court held that the final decision of the Court of Appeals recognized the spouses Timoteo Bandales and Agatona Decena as the previous owners of the land, and it was established that Timoteo Bandales entrusted the land to Decena in 1927. Therefore, Decena was entrusted the land by its true owner. The tenancy relationship is not extinguished by the death of the landholder or the transfer of legal possession. Under Section 9 of Republic Act 1199, as amended, the purchaser, transferee, or heir assumes the rights and obligations of the former landholder. Consequently, the respondents, as heirs, assumed the obligations of the original landholder, and Decena had a right to continue as tenant. The Court ordered Decena’s reinstatement as tenant of the subject lots. No damages were awarded, as the dispossession was via a court-ordered writ of execution, and the improvements would not need reimbursement since Decena was being reinstated.